Guidelines and Code of Conduct

Foreword

Our guidelines and our Code of Conduct form a binding Code of Ethics for all employees at all levels. It ensures equitable interpersonal relationships at work, with our business partners as well as ensuring compliance with national and international laws. Every DEUTA employee is expected to read this Code of Ethics, to internalise it and to put it into practice every day at work.

DEUTA’s Commitments

Solution Provider operating worldwide in the areas of Rail traffic and the Automotive industry in the areas of ‘Train Control Systems’ und ‘Precision Engineering’

Subscribing to the traditions of its founders

Observing laws according to the Code of Conduct

Subscribing to goal-oriented openness towards all partners according to the code of conduct

Putting into practice the basic principles of Total Quality Management

Ecological orientation for the protection of environment and employees, i.e. Complying with laws in the area of environment and work safety as well as the strengthening of environmentally responsible behaviour

DEUTA’s Objectives

Ensuring continuous profitability

Durable autonomy and independence of the company

Profit sharing for shareholders and employees

Transparency of objectives and strategies throughout the company

Continuous improvements of procedures, processes and patterns of behaviour

DEUTA Code of Conduct

Deuta will not tolerate any infringement by its employees of the law whether this be national or international law. Where this arises, every employee, apart from the legal sanctions resulting from infringements of contractual duties, will face consequences under employment law.

Guiding principles

For Deuta and its employees, the legal provisions represent only the minimum standards required for responsible and successful business activity. They feel committed to a corporate culture which lays down much higher ethical standards according to the following principles:

Deuta and its employees are committed, out of a sense of fairness, to the basic principles of fair competition.

a) It is prohibited to prevent or restrict in any way competition between Deuta and its competitors, i.e. prohibition on so-called horizontal competition agreements, b) It is prohibited to make arrangements and agreements between Deuta and its customers or licence holders, i.e. prohibition on so-called vertical competition agreements c) It is prohibited to abuse a dominant market position (e.g. prohibition on discriminatory treatment of customers without factual justification, refusal to deliver, selective distribution, implementation of unreasonable purchase/sales prices and conditions etc.)

Accepting and gaining unfair advantage

Deuta and its employees oppose to any form of acceptance of and gaining from unfair advantage, including corruption.

a) Accepting unfair advantage Prohibition on the acceptance of unfair advantage in relation to business partners or third parties in the form of direct or indirect bribes, ‘acceleration money’, gifts or payments etc. (except of occasional gifts, hospitality or other contributions of low value having no bearing on the business decision); Prohibition on the acceptance of unfair advantage on the part of contracted advisors, intermediaries, agents or comparable third parties; prohibition on the acceptance of unfair advantage with respect to public officials at home or abroad.

b) Gaining unfair advantage Prohibition on gaining unfair advantage from business partners or third parties in the form of payments, gifts or other material benefits (except of occasional gifts of low value or appropriate business related invitations); Obligation on Deuta employees to inform their respective line managers of benefits offered to them of more than low value; Prohibition on gaining unfair advantage leading to financial, legal or personal betterment (e.g. free or reduced price travel, use of motor vehicle, admission tickets as well as other discounts etc).

Donations

In particular cases, Deuta makes donations, in cash and in kind, to social, artistic, cultural and scientific causes. Contributions made to look like donations (fake donations) are a violation of the transparency prohibition. The following rules shall be observed for the allocation of donations: a) No payments to be made to private accounts b) No donations to be made to persons or organisations of dubious reputation c) Compliance with the Transparency principle d) Prohibition on donations which could affect, even minimally, the decision processes of business partners and third parties in relation to Deuta

Money laundering

No employee of Deuta may, working alone or in collaboration with business partners or third parties, take measures which violate regulations regarding money laundering, whether at home or abroad.

Embargo and export control regulations

All Deuta employees are obliged to comply with prevailing embargo and export control regulations.